7 October 2016 APFF Roundtable Q. 18, 2016-0652791C6 F - Taxable Canadian property and Part XIII tax -- summary under Section 119

Will CRA provide the s. 119 credit respecting dividends paid on shares which are not taxable Canadian property but which have been deemed to be disposed of by virtue of s. 128.1(4)? In responding negatively, CRA stated:

[S]ection 119… provides that…the property deemed to have been disposed of must be capital property that was a TCP throughout the period beginning with the emigration and ending at the time of the actual disposition of the property.